Laura Muzi
Abstract
This article examines how transparency can function as a foundational safeguard in algorithmic governance within the European legal space. The Council of Europe’s Framework Convention provides a broad, rights-oriented vision of transparency grounded in intelligibility, oversight and participation. In contrast, the EU AI Act adopts a predominantly technical, market-driven approach, offering complementary but more limited transparency obligations. The paper argues that national administrative law plays a crucial role in operationalising these frameworks by articulating transparency as a multi-layered principle – combining access to information, reason-giving, participation and review – to address the structural opacity of AI systems. Through this administrative infrastructure, algorithmic decision-making can be reconciled with democratic accountability and the rule of law.
TABLE OF CONTENTS
Transparency as the missing link in AI Governance
Transparency and the CoE Framework Convention
Beyond the AI Act: Transparency as an administrative principle
Transparency as a Democratic Safeguard
